Research Theme

International Tax

Low-income countries are more dependent on corporate income tax revenue than richer countries, and at the same time, disproportionately affected by multinational tax avoidance. Our research on this theme investigates ways in which developing countries can protect their tax bases, including through simplified transfer pricing methods and improved tax treaty policies. It also examines the challenges and opportunities developing countries face from their participation in international tax negotiations.

ICTD has also been closely following the developments around the UN Tax Convention. Check out our latest research and analysis here.

Led By

Martin Hearson

Key Resources

Working Paper

Global Rules, Local Realities: Lessons from the Global South on International Tax Standards

June 2026

Martin Hearson, Frederik Heitmüller, Florian Dierich

Working Paper

Scenarios for Negotiating a UN Framework Convention on International Tax

January 2025

Frederik Heitmüller

Partner Publication

A Fairer Global Tax Architecture

September 2024

Martin Hearson, Frederik Heitmüller, Mbakiso Magwape, Suranjali Tandon

Journal Article

Relieving Double Taxation on Cross-Border Services: A Comparative Analysis of Major Exporting Countries

July 2026

Frederik Heitmüller, Aisha Aize Isa, Florian Dierich, Yvette Nakibuule Wakabi

International Tax Library

Working Paper

Taxing Profits from International Maritime Shipping in Africa: Past, Present and Future of UN Model Article 8 (Alternative B)

November 2021

Bob Michel, Tatiana Falcão

Working Paper

Tax Treaty Aggressiveness: Who is Undermining Taxing Rights in Africa?

November 2021

Lucas Millán-Narotzky, Javier García Bernardo, Maïmouna Diakité, Markus Meinzer

Book

The Politics and History of Global Tax Governance

September 2021

Martin Hearson, Thomas Rixen

Partner Publication

Using New Data to Support Tax Treaty Negotiation

July 2021

Martin Hearson, Marco Carreras, Anna Custers

Working Paper

The Contested Shaping of International Tax Rules: The Growth of Services and the Revival of Fractional Apportionment

July 2021

Sol Picciotto

Partner Publication

Tax Treaties of G-24 Countries: Analysis Using a New Dataset

May 2021

Martin Hearson

Journal Article

“An Unacceptable Surrender of Fiscal Sovereignty:” The Neoliberal Turn to International Tax Arbitration

May 2021

Martin Hearson, Todd Tucker

Book

Imposing Standards: The North-South Dimension to Global Tax Politics

May 2021

Martin Hearson

Working Paper

Profit Shifting of Multinational Corporations Worldwide

March 2021

Javier García Bernardo, Petr Janský

Research in Brief

At the Table, Off the Menu? Assessing the Participation of Lower-Income Countries in Global Tax Negotiations

December 2020

Rasmus Corlin Christensen, Martin Hearson, Tovony Randriamanalina

Working Paper

At the Table, Off the Menu? Assessing the Participation of Lower-Income Countries in Global Tax Negotiations

December 2020

Rasmus Corlin Christensen, Martin Hearson, Tovony Randriamanalina

African Tax Administration Paper

Tax Amnesties in Africa: An Analysis of the Voluntary Disclosure Programme in Uganda

December 2020

Solomon Rukundo

10 August 2026

The UN Tax Convention draft protocol on cross-border services: clear direction but crucial details left open

Frederik Heitmüller

The much awaited Co-Lead’s draft protocol on the taxation of income from cross-border services was published on 20 July 2026….

4 August 2026

Double taxation relief on remote services – implications for UN Tax Convention Protocol 1 negotiations

Frederik Heitmüller, Aisha Aize Isa, Florian Dierich, Yvette Nakibuule Wakabi

To inform ongoing negotiations on the taxation of cross-border services at the UN, we wrote a study on double tax…

26 November 2025

A new era or business as usual? Why the UN Expert Committee on Tax is still relevant

Florian Dierich

The Committee’s most prominent contribution is the UN Model Tax Convention, which provides model language for the negotiation of bilateral…

4 November 2025

UN Tax Convention Reading List Part 3: Protocol 2 – Dispute Resolution and Prevention

Florian Dierich, Frederik Heitmüller

In Part 3 of our UN Tax Convention reading list, we bring together key research and analysis on dispute prevention…

31 October 2025

UN Tax Convention Negotiations: Where are we at and where are we headed?

Frederik Heitmüller, Florian Dierich

In preparation for the Nairobi session, two documents were shared for discussion: a Framework Convention Template prepared by the Co-lead…

8 October 2025

UN Tax Convention reading list part 2: Protocol 1 – Taxation of cross-border services

Florian Dierich, Frederik Heitmüller

The negotiations for Protocol 1 present a genuine opportunity to revisit how cross-border services are taxed. But, as we explored…

19 January 2023

Call for Applications: Four fully-funded PhD scholarships in tax and development

The International Centre for Tax and Development (ICTD) is a research centre aiming to improve tax policy and administration in…

1 August 2022

Call for abstracts: Research colloquium on global tax governance

GLOBTAXGOV and the ICTD are inviting submissions of abstracts to discuss early-stage original research for the fourth season of the…

12 July 2022

Job Opportunity: Post-Doctoral Researcher (International Tax)

Closing date for applications: Sunday 21st August 2022…

13 April 2022

Job Opportunity: Senior Communications Consultant, DIGITAX Programme

Closing date for applications: May 8th, 2022 The International Centre for Tax and Development (ICTD) is looking to hire a…

28 January 2022

Call for abstracts: Research colloquium on global tax governance

After the first two successful seasons of the research colloquium on global tax governance co-organised by GLOBTAXGOV and Martin Hearson…

8 December 2021

Launch of the Tax Treaties Explorer: New Data for Better Negotiation

Tax Treaties and Developing Countries The use of tax treaties by developing countries is controversial: Best case scenario? Tax treaties…

Academic Symposium on the UN Framework Convention on International Tax Cooperation

Virtual

6 February 2026 – 15:30

•

Timezone: Europe/London

ICTD Research Director Martin Hearson and Associate Postdoctoral Fellow Frederik Heitmüller will be speaking at the Academic Symposium on the UN Framework Convention on International Tax Cooperation, hosted by the International Tax Program at the NYU School of Law.

Lecture: The need for more inclusive, equitable tax and multilateral systems

Virtual

3 December 2025 – 16:00

•

Timezone: Europe/London

Fresh from the UN Tax Convention negotiations in Nairobi earlier this month, Mukumba will discuss why reforming the global tax architecture matters for everyone, not just the global South that is pushing for change.

Conference: Digital Service Taxes: A fair and effective way to tax the data economy?

In person

25 September 2025 – 13:30

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Timezone: Europe/London

Allard Pierson Museum, Oude Turfmarkt, Amsterdam, Netherlands

ICTD Research Officer Florian Dierich will be presenting the Centre’s research in a panel exploring policy options around an “improved DST” compared to other alternatives.

WEBINAR: Next Steps for the UN Convention on Tax: Mapping Priorities

Virtual

16 July 2025 – 14:00

•

Timezone: Europe/London

Countries around the world are losing billions to illicit financial flows, tax avoidance, tax evasion, and unfair allocation of taxing rights—reflecting a global tax framework which is no longer fit for purpose. The UN Framework Convention on International Tax Cooperation